Section 68 cast onus on assessee to explain source of source of share subscription

Onus is on the assessee company to bring on record the cogent evidences to prove the identity and creditworthiness of the share subscribers and genuineness of the transaction which in the instant case the assessee is not able to prove the same as per the facts emerging from the records and material before us as set out above and in our considered view in the instant case the transactions were nominal rather than real.

The creditworthiness of the shareholders is not proved because they did not had their own money as every chequ

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